EPA Checklist for PM2.5 SIP Submittals

SIP submitted by: Pennsylvania Department of Environmental Protection for the Attainment Demonstration and Base Year Inventory for 

the Pennsylvania portion of the Philadelphia-Wilmington, PA-NJ-DE PM2.5 Nonattainment Area

Date submitted: April 12, 2010

Purpose: 

This checklist has been prepared by EPA staff for use in reviewing PM2.5 SIP submittals that are due to EPA by April 5, 2008, from each State 

having a nonattainment area designation that became effective on April 5, 2005. This checklist is intended to summarize the requirements of Part 

51, Appendix V, “Criteria for Determining the Completeness of Plan Submissions,” and Part 51, Subpart Z, “Provisions for Implementation of PM2.5

National Ambient Air Quality Standards.” Also included are sections on the applicability requirements of Part 93, Subpart A, “Conformity to 

State/Federal Implementation Plans of Transportation Plans, Programs, and Projects,” and the compliance monitoring requirements of Part 51, 

Subpart K, “Source Surveillance.” This checklist is not a regulation and does not change or substitute for any legal requirements of the Clean Air 

Act (CAA) or applicable rules. Any decisions regarding the approvability of a particular SIP will be made based on the requirements of the CAA and 

the relevant regulations. Interested parties are free to raise questions and objections to this checklist or to its use in a particular situation.

Acronyms and Terms:

CAA is Clean Air Act

CAIR is Clean Air Interstate Rule

EI is emissions inventory

MV is motor vehicle

NAA is nonattainment area

NAAQS is national ambient air quality standards

NH3 is ammonia

NOx is nitrogen oxides

RACM is reasonably available control measures

RACT is reasonably available control technology

RFP is reasonable further progress

SIP is state implementation plan

SO2 is sulfur dioxide
Notes on use of this checklist:

(1) For all items in the checklist with boxes under the “Completeness” column, users should mark the first box as “Y” (yes), “N” (no), or “N/A” (not 

applicable). An “N” (no) response may indicate a deficiency in the SIP submittal. “Y” and “N/A” responses indicate completeness of the item in 

the SIP and do not reflect on approvability of the item. The second box is for recording the location of the item in the SIP submittal.

(2) Several items in the checklist do not have boxes to mark under the “Completeness” column. These items are not intended as part of an initial SIP 

completeness check but are included to assist reviewers in assessing the approvability of a SIP submittal.

References:

(1) “EI Guidance”: Emission Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality

Standards (NAAQS) and Regional Haze Regulations (August 2005)

(http://www.epa.gov/ttn/chief/eidocs/eiguid/eiguidfinal_nov2005.pdf)

(2) “Modeling Guidance”: Guidance on Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, 

PM2.5 and Regional Haze (April 2007)

(http://www.epa.gov/ttn/scram/guidance/guide/final-03-pm-rh-guidance.pdf)

(3) “Road Dust Guidance”: Policy Guidance on the Use of the November 1, 2006, Update to AP-42 for Re-entrained Road Dust for SIP 

Development and Transportation Conformity (August 2, 2007)

(4) “110(a) Guidance”: Guidance on SIP Elements Required Under section 110(a)(1) and (2) for the 1997 8-hour Ozone and PM2.5 National 

Ambient Air Quality Standards (October 2, 2007)

(http://www.epa.gov/ttn/caaa/t1/memoranda/110a_sip_guid_fin100207.pdf)

(http://www.epa.gov/ttn/chief/ap42/ch13/related/rel13s02_memo080207.pdf)

(5) “PM Impl. Rule”: Clean Air Fine Particle Implementation Rule, 72 FR 20586 (April 25, 2007)

(http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-6347.pdf)

(6) “Transp. Conf. Rule”: Transportation Conformity Rule Amendments for the New 8-hour Ozone and PM2.5 National Ambient Air Quality 

Standards and Miscellaneous Revisions for Existing Areas; Transportation Conformity Rule Amendments: Response 

to Court Decision and Additional Rule Changes, 69 FR 40004 (July 1, 2004)

(http://a257.g.akamaitech.net/7/257/2422/06jun20041800/edocket.access.gpo.gov/2004/pdf/04-14213.pdf)

(7) “SIP Preparation Rule”: Air Quality Implementation Plans; Restructuring SIP Preparation Regulations, 51 FR 40656 (November 7, 1986)

(8) “CE Rule” Credible Evidence Revisions, 62 FR 8328 (February 24, 1997)

(http://www.epa.gov/EPA-AIR/1997/February/Day-24/a4196.pdf)
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

Administrative Requirements from Part 51, Appendix V

2.0. Criteria

2.1(a) Has a letter of submittal from the governor/designee, 

requesting EPA approval of the SIP been received?

Y Letter dated 

04/12/10 from 

John Hanger, 

Secretary, PADEP 

to Shawn M. 

Garwin, RA.

2.1(b)

Has the State provided evidence it has adopted the legally 

enforceable portions of the plan in the State code or body of 

regulations; or issued the necessary permits, orders, and 

consent agreements in final form?

Y Letter dated 

04/12/10 from 

John Hanger, 

Secretary, PADEP 

to Shawn M. 

Garvin, RA and a 

copy of the plan,“ 

State 

Implementation 

Plan Revision: 

Attainment 

Demonstration and 

Base Year 

Inventory

Pennsylvania 

portion of the 

PhiladelphiaWilmington, PANJ-DE Fine 

Particulate 

Nonattainment 

Area,” dated April 

2010.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

2.1(c) Has the State provided evidence it has the necessary legal 

authority under State law to adopt and implement the plan?

Y Legislative 

authority for the 

Pennsylvania air 

quality program 

relating to the 

responsibilities in 

the CAA is 

codified in the 

Pennsylvania Air 

Pollution Control 

Act, 35 P.S. 

§§4001-4015 

(APCA), including 

in section 4 of the 

APCA, which give 

the PADEP the 

power and duty to 

implement the 

provisions of the 

CAA in the 

Commonwealth. 

35 P.S. §§4004(1).
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

2.1(d) Has the official State regulation/document been 

signed/stamped/dated by the appropriate State official 

indicating that it is fully enforceable by the State?

Y A copy of the plan,

“State 

Implementation 

Plan Revision: 

Attainment 

Demonstration and 

Base Year 

Inventory

Pennsylvania 

portion of the 

PhiladelphiaWilmington, PANJ-DE Fine 

Particulate 

Nonattainment 

Area,” dated 

November 2010.

2.1(d) The submittal should include a copy of the actual regulation, or document submitted for approval 

and incorporation by reference into the plan, including indication of the changes made (such as, 

redline/strikethrough) to the existing approved plan, where applicable. The submittal shall be a 

copy of the official State regulation /document signed, stamped and dated by the appropriate 

State official indicating that it is fully enforceable by the State. The effective date of the 

regulation/document shall, whenever possible, be indicated in the document itself. 

2.1(d) If the State submits an electronic copy, it must be an exact duplicate of the hard copy with 

changes indicated. Signed documents need to be in portable document format, rules need to be 

in text format. Files need to be submitted in manageable sizes (e.g., a file for each section or 

chapter, depending on size, and separate files for each distinct document) unless otherwise 

agreed to by the State and Regional Office.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

2.1(e) Has the State provided evidence it followed all of the 

procedural requirements of the State’s laws and constitution 

in the adoption/issuance of the plan?

Y Letter dated 

04/12/10 from John 

Hanger, Secretary, 

PADEP to Shawn 

M. Garvin, RA; 

copy of the Notice 

“Proposed Revision 

to the State 

Implementation Plan 

for the PhiladelphiaWilmington, PA-NJDE Pennsylvania 

Fine Particulate 

Nonattainment Area; 

Public Hearing” 

published in the 

Saturday, February 

6, 2010 edition of 

the Pennsylvania 

Bulletin [40 Pa.B. 

756]; and a copy of 

the affidavit of 

publication and of 

the public notice.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

2.1(f) Has the State provided evidence that public notice was given 

of the proposed change consistent with procedures approved 

by EPA, including the date of publication of such notice?

Y Pennsylvania 

published a public 

notice of the 

proposed revision 

to the SIP and a 

notice of a public 

hearing on the 

proposed changes 

in the 

Pennsylvania 

Bulletin on 

February 6, 2010 

[40 Pa.B. 756]. A 

copy of the 

affidavit of 

publication and the 

public notice was 

published in the 

February 5, 2010, 

edition of the 

Bucks County 

Courier Times. 

2.1(g) Has the State provided a certification that public hearings(s) 

were held in accordance with the information provided in the 

public notice and the State’s laws and constitution, if 

applicable, and consistent with the public hearing 

requirements in 40 CFR 51.102?

Y The SIP submittal 

letter dated 

04/12/10 from 

John Hanger, 

Secretary, PADEP 

states that the 

public hearing was 

held on March 11, 

2010, in 

Norristown, PA.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

2.1(h) Has the State provided a compilation of public comments 

and the State’s response thereto?

Y The SIP submittal 

letter dated 

04/12/10 from 

John Hanger, 

Secretary, PADEP 

states that a 

comment and 

response document 

was not prepared 

because no 

comments were 

received.

Technical Requirements from Part 51, Subpart Z

§51.1002 Submittal of State implementation plan.

51.1002(a) Was the SIP submitted within 3 years from the date of 

designation?

N Submitted April 

12, 2010.

- PM Impl. Rule, 20587, 

20599

51.1002(b) The State must submit a plan consistent with the requirements of section 110(a)(2) of the Act 

unless the State already has fulfilled this obligation for the purposes of implementing the PM2.5

NAAQS.

- 110(a) Guidance

51.1002(c) Does the SIP identify and evaluate sources of PM2.5 direct 

emissions and PM2.5 attainment plan precursors? 1

Y Section I. 

Introduction and 

Overview.

- EI Guidance (Section 3.2)

- PM Impl. Rule, 20651-

20655. 

51.1002(c)(1) Does the SIP address SO2 as a PM2.5 attainment plan

precursor and evaluate sources of SO2 emissions in the State 

for control measures?

Y Section I. 

Introduction and 

Overview.

- PM Impl. Rule, 20594

 

1

After January 1, 2011, for purposes of establishing emissions limits under 51.1009 and 51.1010, States must establish such limits taking into consideration the condensable 

fraction of direct PM2.5 emissions. Prior to this date, States are not prohibited from establishing source emission limits that include the condensable fraction of direct PM2.5. 
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1002(c)(2) If the State and EPA have not provided an appropriate 

technical demonstration for a specific area showing that NOx 

emissions from sources in the State do not significantly

contribute to PM2.5 concentrations in the nonattainment area, 

does the SIP address NOx as a PM2.5 precursor and evaluate 

sources of NOx emissions in the State for control measures?

Y Section I. 

Introduction and 

Overview.

- PM Impl. Rule, 20594,

20597

51.1002

(c)(3)(i)-(ii)

If the State or EPA has provided a demonstration showing 

that the State’s VOC emissions significantly contribute to 

PM2.5 concentrations in the NAA, has the State addressed 

VOC as a PM2.5 attainment plan precursor and evaluated 

sources of VOC emissions in the State for control measures?

N/A Section I. 

Introduction and 

Overview.

- PM Impl. Rule, 20592,

20597

51.1002

(c)(4)(i)-(ii)

If the State or EPA has provided a demonstration showing 

that the State’s NH3 emissions significantly contribute to 

PM2.5 concentrations in the NAA, has the State addressed 

NH3 as a PM2.5 attainment plan precursor and evaluated 

sources of NH3 emissions in the State for control measures?

N/A Section I. 

Introduction and 

Overview.

- PM Impl. Rule, 20591,

20597

51.1002(c)(5) If the administrative record related to development of the 

State’s SIP shows that the presumption in the PM2.5

Implementation Rule for a PM2.5 precursor with respect to a 

particular NAA is not technically justified, has the State 

submitted a demonstration to reverse that presumption?

N/A - PM Impl. Rule, 20597

§51.1004 Attainment dates.

51.1004(a) Is the proposed attainment date as expeditious as practicable, 

but no later than 5 years from the date the area was 

designated nonattainment, or no later than 10 years from 

designation in the event the state is proposing an extension?

Y Section I. 

Introduction and 

Overview.

- PM Impl. Rule, 20600, 

20601, 20602, 20612-

20614. See also 

RACT/RACM 

requirements and 

preamble language.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1004(a) Preamble interpretation of 51.1004(a) indicates that the attainment date that is “as expeditious as 

practicable” should reflect the projected impact of:

(1) existing programs (e.g., partial implementation of the CAIR rule, final Acid Rain Program, 

motor vehicle tier II standards and heavy-duty diesel engine standards, NOx SIP call, State 

legislation and rules),

(2) expeditious implementation of all RACM and RACT local control measures, and

(3) potential reasonable measures to reduce intrastate transport emissions from sources within 

the State’s jurisdiction.

- PM Impl. Rule, 20600, 

20601, 20602, 20612, 

2013, 20614. See also 

RACT/RACM 

requirements and 

preamble language. See 

also 51.2007(b).

51.1004(b) Has the State submitted an attainment demonstration

justifying its proposed attainment date? 

Y Section V. 

Attainment 

Demonstration and 

Weight of 

Evidence (WOE).

- PM Impl. Rule, 20600

51.1004(b) If the state is proposing an attainment date later than 5 years from the area’s date of designation, 

has the state provided a justification for the extension based on the severity of nonattainment and 

the availability and feasibility of pollution control measures?

- PM Impl. Rule, 20600-

20602, 20612-20614

- See also RACT/RACM 

requirements and 

preamble language.

§51.1007 Attainment demonstration and modeling requirements.

51.1007(a) The State must submit an attainment demonstration for any area designated as nonattainment 

showing that the area will attain the annual and 24-hour standards as expeditiously as 

practicable.

- PM Impl. Rule, 20601

51.1007(a) The attainment demonstration must meet the requirements of:

- §51.112 (Demonstration of control strategy adequacy), and

- Appendix W to part 51 (Guideline on Air Quality Models).

- PM Impl. Rule, 20608

- EI Guidance 

- Modeling Guidance

51.1007(a) Does the attainment demonstration include all of the items 

below as part of the basis for the State’s projected attainment 

date?

- EI data

- modeling results

- emission reduction analyses

Y Appendices A 

through H.

- PM Impl. Rule, 20647, 

20605
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1007(a) The attainment date justified by the demonstration must be consistent with the requirements of 

§51.1004(a).

- PM Impl. Rule, 20609

- Modeling Guidance 

(Section 3.5)

51.1007(a) The modeled strategies in the demonstration must be consistent with the requirements of:

- §51.1009 for RFP, and

- §51.1010 for RACT and RACM.

- PM Impl. Rule, 20610-

20632

- PM Impl. Rule, 20633-

20640 

51.1007(a) The attainment demonstration and supporting air quality modeling should be consistent with 

EPA’s PM2.5 modeling guidance.

- Modeling Guidance

51.1007(b) For all control measures needed for attainment, the SIP must provide for implementation as 

expeditiously as practicable, but no later than the beginning of the year prior to the attainment 

date.

- PM Impl. Rule, 20610

§51.1008 Emission inventory requirements for the PM2.5 NAAQS.

51.1008(a)(1) Has the State submitted statewide EIs (under subpart A) for 

direct PM2.5 emissions and emissions of PM2.5 precursors?

Y Appendices B2 

and C2. 

- EI Guidance 

51.1008(a)(2) Has the State submitted any additional EI information needed 

to support an attainment demonstration and RFP plan

ensuring expeditious attainment of the annual and 24-hour

PM2.5 standards?

Y –

attainment 

demo

N/A - RFP

Appendices B2 

and C2.

- EI Guidance (Section 

3.3.2)

51.1008(b) Has the State submitted a baseline EI for the attainment 

demonstration under §51.1007, and for meeting RFP 

requirements under §51.1009?

Y –

attainment 

demo

N/A - RFP

Appendices B2 

and C2.

- PM Impl. Rule, 20647

- EI Guidance 

§51.1009 Reasonable further progress (RFP) requirements. 2

51.1009(c) If the SIP demonstrates the area needs an attainment date of 

more than five years from the date of designation, has the 

State submitted a separate RFP plan?

N/A See footnote 2 - PM Impl. Rule, 20633

 

2 A separate RFP plan is not required for an area if the State submits to EPA an attainment demonstration and State implementation plan demonstrating the area will attain the PM 

NAAQS within five years of the date of designation.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1009(c)(1) If the SIP justifies an attainment date greater than five and 

less than nine years from the date of designation, does the 

RFP plan include 2009 emissions milestones for direct PM2.5

and PM2.5 attainment plan precursors demonstrating RFP for 

the 2009 emissions year?

N/A See footnote 2 - PM Impl. Rule, 20634

51.1009(c)(2) If the SIP justifies an attainment date of nine or ten years 

from the date of designation, does the RFP plan include 2009 

and 2012 emissions milestones for direct PM2.5 and PM2.5

attainment plan precursors demonstrating RFP for the 2009 

and 2012 emissions years?

N/A See footnote 2 - PM Impl. Rule, 20634

- PM Impl. Rule, 20640

51.1009(d) The RFP plan must demonstrate generally linear progress in reducing emissions between the 

base year and the attainment year.

- PM Impl. Rule, 20634

51.1009(e) For a multi-State nonattainment area, is RFP demonstrated 

on the basis of common multi-State inventories?

N/A See footnote 2 - PM Impl. Rule, 20640

51.1009(e) For a multi-State nonattainment area, have the States 

submitted a coordinated RFP plan?

N/A See footnote 2 - PM Impl. Rule, 20640

51.1009(e) For a multi-State nonattainment area, has each State ensured 

its sources comply with enforceable emission levels and 

other requirements that in combination with the reductions 

planned in other state(s) will provide for attainment as 

expeditiously as practicable and demonstrate RFP?

N/A See footnote 2 - PM Impl. Rule, 20640

51.1009(f) In the benchmark RFP plan, has the State:

- identified direct PM2.5 emissions and PM2.5 attainment 

plan precursors regulated under the PM2.5 attainment plan, 

and

- specified target emission reduction levels to be achieved 

during the milestone years?

N/A See footnote 2 - PM Impl. Rule, 20639

51.1009(f) In developing the benchmark RFP plan, has the State 

developed EI information for the geographic area included in 

the plan?

N/A See footnote 2 - PM Impl. Rule, 20636-

20639
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1009(f)(1) For direct PM2.5 emissions and each addressed PM2.5 precursor, the full implementation 

reduction must be calculated by subtracting the full implementation inventory from the baseline 

year inventory.

- PM Impl. Rule, 20639

51.1009(f)(2) The “milestone date fraction” must be calculated as the ratio of the number of years from the 

baseline year to the milestone inventory year divided by the number of years from the baseline 

year to the full implementation year.

- PM Impl. Rule, 20639

51.1009(f)(3) For direct PM2.5 emissions and each addressed PM2.5 precursor, the benchmark emission 

reduction must be calculated by multiplying the full implementation reduction by the milestone 

date fraction.

- PM Impl. Rule, 20639

51.1009(f)(4) The benchmark emission level in the milestone year must be calculated for direct PM2.5

emissions and each PM2.5 attainment plan precursor by subtracting the benchmark emission 

reduction from the baseline year emission level.

- PM Impl. Rule, 20639

51.1009(f)(5) In comparing EIs between baseline and future years for direct PM2.5 emissions and each PM2.5

precursor, the EIs must be derived from the same geographic area.

- PM Impl. Rule, 20636

51.1009(f)(5) The plan must include emissions estimates for all types of emitting sources and activities in the 

geographic area from which the EIs for direct PM2.5 emissions and each PM2.5 precursor 

addressed in the plan are derived.

- PM Impl. Rule, 20636

51.1009(f)(6) Has the State included in its RFP submittal an inventory of 

on-road mobile source emissions in the PM2.5 nonattainment 

area for purposes of establishing motor vehicle emissions

budgets for transportation conformity (as required in 40 CFR 

part 93)? (Note section on “Applicability Requirements from 

Part 93” below.)

N/A See footnote 2 - PM Impl. Rule, 20645

51.1009(g) The RFP plan must demonstrate emissions for the milestone year are either:

(1) At levels that are roughly equivalent to the benchmark emission levels for direct PM2.5

emissions and each precursor to be addressed in the plan; or

(2) At levels included in an alternative scenario projected to result in a generally equivalent 

improvement in air quality by the milestone year as would be achieved under the benchmark 

RFP plan.

- PM Impl. Rule, 20639
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.1009(h) If applicable, the equivalence of an alternative scenario to the corresponding benchmark plan 

must be determined by comparing the expected air quality changes of the two scenarios at the 

design value monitor location. This comparison must use the information developed for the

attainment plan to assess the relationship between emissions reductions of the direct PM2.5

emissions and each PM2.5 attainment plan precursor addressed in the attainment strategy and the 

ambient air quality improvement for the associated ambient species.

- PM Impl. Rule, 20639

§51.1010 Requirements for RACT and RACM.

51.1010(a) The State must submit a SIP revision demonstrating it has adopted all RACM (including RACT)

necessary to achieve attainment as expeditiously as practicable and to meet any RFP 

requirements.

- PM Impl. Rule, 20610-

20632

51.1010(a) Does the SIP revision contain:

- the list of the potential measures considered by the State, 

and

- information and analysis to support the State’s judgment 

that it has adopted all RACM, including RACT?

Y Section IV.B. - PM Impl. Rule, 20610-

20632

51.1010(b) In determining whether a particular emission reduction

measure or set of measures must be adopted as RACM under

section 172(c)(1) of the CAA, has the State considered the

cumulative impact of implementing the available measures?

Y Section IV.C. - PM Impl. Rule, 20610-

20632 (20614)

51.1010(b) Potential measures that are reasonably available considering technical and economic feasibility

must be adopted as RACM if, considered collectively, they would advance the attainment date 

by one year or more.

- PM Impl. Rule, 20611, 

20614, 20617

§51.1012 Requirement for contingency measures.

51.1012(a) Consistent with section 172(c)(9) of the Act, has the State

submitted specific contingency measures to be undertaken if 

the area fails to make RFP, or fails to attain the PM2.5

NAAQS by its attainment date?

Y Section VI.B. - PM Impl. Rule, 20643

51.1012(a) Does the submittal indicate the above contingency measures

must take effect without significant further action by the

State or EPA?

Y Section VI.A. - PM Impl. Rule, 20643

Applicability Requirements from Part 93, Subpart A (Transportation Conformity)
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

§93.102 Applicability.

93.102(b)(1) Does the SIP include one of the following:

- a MV emissions budget established for direct PM2.5, or

- a demonstration that regional on-road mobile source 

emissions are an insignificant contributor to the PM2.5 air 

quality problem as provided under the transportation 

conformity rule (40 CFR 93.109(k))? 

Y Section III.E. - PM Impl. Rule, 20645-

20646

93.102(b)(2)(v) Does the SIP include one of the following:

- a MV emissions budget established for direct SO2, or

- a demonstration that regional on-road mobile source 

emissions are an insignificant contributor to the SO2 air 

quality problem as provided under the transportation 

conformity rule (40 CFR 93.109(k))?

Y Section III.E. - PM Impl. Rule, 20645-

20646

93.102(b)(2)(iv) Does the SIP include one of the following:

- a MV emissions budget established for NOx, or

- a demonstration that regional on-road mobile source 

emissions are an insignificant contributor to the PM2.5 air 

quality problem as provided under the transportation 

conformity rule (40 CFR 93.109(k)), or

- a demonstration that NOx is not an attainment plan 

precursor as provided in 40 CFR 51.1002(c)(5)?

Y Section III.E. - PM Impl. Rule, 20645-

20646

93.102(b)(2)(v) Does the SIP include one of the following:

- a MV emissions budget established for VOC, or

- a demonstration that regional on-road mobile source 

emissions are an insignificant contributor to the PM2.5 air 

quality problem as provided under the transportation 

conformity rule (40 CFR 93.109(k)), or

- a demonstration that VOC is not an attainment plan 

precursor as provided in 40 CFR 51.1002(c)(5)? 

Y Section III.E. - PM Impl. Rule, 20645-

20646
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

93.102(b)(2)(v) Does the SIP include one of the following:

- a MV emissions budget established for ammonia, or

- a demonstration that regional on-road mobile source 

emissions are an insignificant contributor to the PM2.5 air 

quality problem as provided under the transportation 

conformity rule (40 CFR 93.109(k)), or

- a demonstration that ammonia is not an attainment plan 

precursor as provided in 40 CFR 51.1002(c)(5)?

Y Section III.E. - PM Impl. Rule, 20645-

20646

93.102(b)(3) If re-entrained road dust emissions are considered a 

significant contributor to the area’s PM2.5 air quality 

problem, does the SIP include these emissions in the direct 

PM2.5 MV emissions budget?

Y –

accounted 

for in direct 

PM budget.

Section III.E. - PM Impl. Rule, 20645

- Transp. Conf. Rule, 

40033-40034

93.102(b)(3) For any re-entrained road dust that is included in the MV emissions budget, the November 2006 

version of AP-42 or an EPA-approved local methodology should be used for estimating such 

emissions.

- Road Dust Guidance

93.122(f) If transportation construction-related fugitive dust emissions 

are considered a significant contributor to the area’s PM2.5 air 

quality problem, does the SIP include these emissions in the 

direct PM2.5 MV emissions budget?

N/A - Transp. Conf. Rule, 

40035-40036

Technical Requirements from Part 51, Subpart K (Source Surveillance)

§51.211 Emission reports and recordkeeping.

51.211(a) & (b) Does the SIP provide procedures for maintaining records of

and periodically reporting to the State the types and amounts 

of emissions as well as information needed to determine 

compliance?

Y Appendix B.1. - SIP Preparation Rule, 

40673

§51.212 Testing, inspection, enforcement, and complaints.

51.212(a) Does the SIP provide for periodic testing and for periodic 

inspection of stationary sources?

3

Y In each control 

measure in Section 

IV.A.

- CE Rule, 8328

 

3 EPA recommends testing at least once per permit term and inspections at least once per year.
Regulatory 

Citation Requirement

Completeness

References

Y, N, or N/A Location in SIP

51.212(c) Does the SIP contain enforceable test methods for each 

specified emission limit?

Y In each control 

measure in Section 

IV.A.

- CE Rule, 8328

§51.214 Continuous emission monitoring.

51.214(a) Does the SIP contain provisions requiring stationary sources 

subject to emissions standards of the plan to install, calibrate, 

maintain, and operate equipment for continuously monitoring 

and recording emissions?

Y The measures have 

CEMs where they

are required by 

EPA.

- SIP Preparation Rule, 

40673

51.214(b) Does the SIP identify the types of sources and source 

categories that must install the continuous monitoring 

equipment and what pollutants must be monitored 

(presumably PM2.5)?4

Y EGUs under CAIR 

are required.

- SIP Preparation Rule, 

40673

51.214(c) Does the SIP, as a minimum, require the types of sources set

forth in Appendix P of part 51 to meet the requirements 

therein for continuous emission monitoring and recording?

Y The measures have 

CEMs where they

are required by 

EPA.

- SIP Preparation Rule, 

40673

51.214(d), (e) 

& (f)

Does the SIP contain provisions requiring stationary sources 

subject to emissions standards of the plan to:

- maintain a file of all pertinent information for at least two 

years,

- submit to the State information relating to emissions and 

operation of the emission monitors, and

- have installed all necessary equipment and to have begun 

monitoring and recording within 18 months of either

approval of the SIP or promulgation by EPA of 

monitoring requirements for a specific source (as a 

minimum, applies to sources set forth in Appendix P of 

part 51)?

Y In each measure 

that relied on the 

SIP.

- SIP Preparation Rule, 

40673

 

4 EPA recommends identifying sources and source categories other than fossil fuel fired steam generators, fluidized bed catalyst cracking unit catalyst regenerators, sulfuric acid 

plants, and nitric acid plants.